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The Gifts, Donations and Hospitality policy establishes the ethical standards of Johnson Tiles and underpins the behaviour we expect of everyone engaged by us in conducting business on our behalf. It enables us to ensure we maintain the first class reputation that our customers, clients and employees expect from us.
The Company's aim is always to ensure customer and client satisfaction. Occasionally, satisfied customers, clients or other third parties may seek to reward employees with gifts. Whilst the Company has no desire to stop deserving employees receiving a small token of gratitude from a satisfied customer or client, there is the potential for abuse. In addition, certain suppliers or contractors may offer “reward schemes” which allow employees to obtain free gifts or discount vouchers in return for ordering services or products on behalf of the Company from that supplier or contractor.
The Company needs to be sure its suppliers and contractors are competitive and that its employees are acting in the best interests of the Company when using a particular supplier or contractor. The Company does not believe that it is appropriate for employees to accept anything of greater value than small tokens of appreciation from customers, clients, suppliers, contractors or from any other person or organisation with which the Company has, or might have, business connections. This is because it is important to ensure that no employee acts in any way that is inconsistent with the integrity of the business by accepting a gift in circumstances where it could influence, or be seen to influence, that employee's business decisions or actions.
For these purposes a “gift” is any payment or item given to an employee on an apparently ex-gratia basis by any party in connection with the employee's employment by the Company.
The company expects its employees to demonstrate honesty, integrity and fairness in all aspects of their business dealings and exercise appropriate standards of professionalism and ethical conduct in all their activities. The company expects the same approach to doing business from everyone acting on its behalf including agents and third parties, and from its suppliers and customers.
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Johnson Tiles does not permit any employee whether directly of indirectly, in a personal of professional capacity to:
1. Accept anything of greater value than small tokens of appreciation (up to £50) from customers, clients, suppliers, contractors or from any other person or organisation with which the company has, or might have business connections.
Any employee receiving a gift must report it to their line manager as soon as it is received and provide details of the nature of the gift and the identity of the sender. Failure to do so will constitutes a disciplinary offence and will be dealt with in accordance with the Company's disciplinary procedure. Depending on the gravity of the offence, this may be treated as gross misconduct in accordance with the Company's disciplinary procedure and could render the employee liable to summary dismissal.
If the gift is anything other than a small token of appreciation having no substantial financial value, the employee will be required to return the gift to the sender with a polite letter thanking them and explaining that it is the Company's policy that employees should not receive gifts.
If, in the opinion of the line manager, the gift might constitute a bribe or other inducement, it will be passed to a Director of the Company who will return it to the sender with a suitable letter explaining the Company's policy and asking the sender to comply with the policy in future.
In cases where the line manager determines that the gift constitutes a small token of appreciation as a personal reward, the employee may be permitted to retain the gift. However, unless the sender of the gift specifically states or makes clear that the gift is intended as a personal reward, all gifts are deemed to be the property of the Company and may be shared amongst members of staff, as appropriate.
Thus, small gifts that are genuinely given as a token of appreciation are acceptable, provided always that they are properly declared in line with this Policy and provided the sender of the gift is not subsequently treated more favourably than other clients, customers, suppliers or contractors.
If the Company discovers that a supplier has been used by an employee wholly or mainly because of the incentive of a free gift (and, as such, the employee has not acted in the best interests of the Company), this will also constitute a disciplinary offence and will be dealt with under the Company's disciplinary procedure. Depending on the seriousness of the offence, it may again be treated as gross misconduct and could render the employee liable to summary dismissal.
The receipt of all gifts will be closely monitored by the Company.
This Policy does not apply to promotional gifts, i.e. items such as pens, calendars or stationery that bear the company name or logo of another organisation, provided that these have no significant financial value.
2. Offer to or receive hospitality from any connected person unless pre-authorised by management or in the case of management the bribery officer.
3. To offer donations either political or charitable to any organisation where anyone in that organisation would constitute a “Connected Person”, unless authorised by management or in the case of management, by the bribery officer.
For these purposes a “Connected Person” is any organisation or individual who has had, or currently has, or is likely to have in the future an influence over the Johnson's business.
To ensure compliance all employees will be provided with a copy of this policy and the company's Anti-Corruption policy, and will be asked to sign it as a condition of their employment. Employees will be required to submit details of all gifts, donations and hospitality to the bribery officer who will record all transactions in a Gifts and Entertaining Register for regular reviewing.
Johnson Tiles' Gifts, Donations and Hospitality Policy, Anti-Corruption Policy and Ethics Policy will be published on the Johnson Tiles' website. The policies will be communicated to customers, suppliers, third parties and agents who will be asked to acknowledge that they have been made aware of the policies and that they will endeavour to adhere to the requirements within.
July 2011 |